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Key Elements of Effective FCPA Remediation: Earning DOJ and SEC's 'High Premium'
The Department of Justice (DOJ) and Securities Exchange Commission's (SEC) Guide to the U.S. Foreign Corrupt Practices Act (FCPA) demonstrates, if there were any doubt, the importance of timely and effective FCPA remediation. Calling it a “high premium,” the DOJ and SEC explain that FCPA remediation can help an organization avoid criminal prosecution and enforcement proceedings; pay reduced penalties and safeguard brand value; and obviate a government-imposed compliance monitor or independent consultant.
It is not just the organization that is impacted by issues arising from poor internal controls. Board members and senior management face substantial embarrassment and damaged personal reputations. Consider also the career damage to business leaders, ethics and compliance officers and internal auditors.
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The DOJ's Corporate Enforcement Policy: One Year Later
The DOJ's Criminal Division issued three declinations since the issuance of the revised CEP a year ago. Review of these cases gives insight into DOJ's implementation of the new policy in practice.
Use of Deferred Prosecution Agreements In White Collar Investigations
This article discusses the practical and policy reasons for the use of DPAs and NPAs in white-collar criminal investigations, and considers the NDAA's new reporting provision and its relationship with other efforts to enhance transparency in DOJ decision-making.
How AI Has Affected PR
When we consider how the use of AI affects legal PR and communications, we have to look at it as an industrywide global phenomenon. A recent online conference provided an overview of the latest AI trends in public relations, and specifically, the impact of AI on communications. Here are some of the key points and takeaways from several of the speakers, who provided current best practices, tips, concerns and case studies.
New York's Latest Cybersecurity Commitment
On Aug. 9, 2023, Gov. Kathy Hochul introduced New York's inaugural comprehensive cybersecurity strategy. In sum, the plan aims to update government networks, bolster county-level digital defenses, and regulate critical infrastructure.